Even as the government moved away from the previous ATO draft ruling to slug pensioners with capital gains tax on death, it also made oodles of money. As the account does not revert to lump-sum phase on death, no anti-detriment top-up benefit can be claimed. These would be quite large, being the cumulative effect of contribution taxes paid during accumulation, since 1988.

When the government giveth, it ever so subtly taketh away. I have a sneaking suspicion the modelling might have shown the government earned a net benefit. Changing the taxation of SMSFs to deny them existing CGT concessions would have involved a significant shift from the present, where tax rules apply identically between SMSFs and other regulated funds.

Even for a government chasing the mirage of a surplus, this would be a big call.